Is cloud computing a challenge to the traditional concept of a permanent establishment?

Introduction – defining cloud computing

The term cloud is used by the information and communication technologies (ICT) industry to indicate, primarily, virtual platforms or infrastructures that allow the execution of codes (services, applications, among others) in various forms across multiple resources, with relevant data.

Region, Europe

BRICS and article 12: international tax policy implications: Part 3

In Parts 1 and 2, Peter Wilson discussed art 12 of the OECD Model Tax Convention and tax treaties involving BRICS. He examined art 12 and discussed why it was relevant and examined the positions of the BRICS on art 12 in the OECD Model. This discussion continues here.

Corporate Taxes, ROW

BRICS and article 12: international tax policy implications: Part 2

The following four intra-BRICS DTCs are substantially the same with taxation in both the source and residence (except for the Russian DTC) country together with the PE and non-arm’s length articles.

Double Taxation, ROW

Investment in Colombia from an international taxation perspective: Part 1

Sylvia H. Torres Caro analyses the concept, advantages and disadvantages of legal stability agreements and double tax treaties in attracting foreign investment, with particular reference to Colombia.

Investment and Indirect Taxes, US/Americas
Corporate Taxes

International Tax Aspects of Islamic Finance: Part 2

AT is levied in EU Member States and is subject to harmonised rules under increasing EU legislation in this area. GST, on the other hand, is a term used by many jurisdictions (eg Pakistan, Australia and Singapore), but describes a different tax or levy depending on the actual jurisdiction.

Corporate Taxes, ROW
Anti-Avoidance

International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning?– Part II

In Part I, Iva Angelova introduced the concept of tax avoidance and explained how trusts are used in tax planning schemes. In Part II, she continues with a discussion on the use of trusts internationally and the role played by Cyprus in the world of tax planning.

Anti-Avoidance, EU Law
Region

Latest developments in the German tax treaty policy

Germany has a wide tax treaty network containing more than 90 tax treaties. Tax treaty negotiations are generally based on the OECD Model Tax Convention and with respect to developing countries on the UN Model Tax Convention.

Double Taxation, Europe
Double Taxation

International Tax Aspects of Islamic Finance: Part 1

Introduction


It should be stated at the outset that this article is not a religious or economic discussion on the topic of Islam and Islamic Finance, nor is it meant to discuss any of the ethical or political issues surrounding these topics.


Corporate Taxes, Double Taxation
Investment and Indirect Taxes

Investment in Colombia from an international taxation perspective: Part 2

In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.

Investment and Indirect Taxes, US/Americas
Practice

International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning? – Part 1

It is evident that at an international level tax planning nowadays is a reality. The purpose of this article is to provide an analysis of how international tax avoidance in the sense of legal minimisation of tax liability can be achieved by the potential use of international trusts. By choosing the correct jurisdiction this practice can prove to be beneficial to all parties and an overview of the advantageous stance Cyprus can have on this matter will be demonstrated.

Anti-Avoidance, EU Law